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HomeMy WebLinkAboutStaff Report 3.B 05/18/2015DATE: May 18, 2015 Agenda Item #3.B TO: Honorable Mayor and Members of the City Council through City Manager FROM: Dan St. John, F.ASCE — Director, Public Works & Utilities Joe Rye — Transit Manager SUBJECT: Resolution Adopting the 2015 Title VI Program for Petaluma Transit RECOMMENDATION It is recommended that the City Council adopt a Resolution Adopting the 2015 Title VI Program for Petaluma Transit. ff., xv ►►�\1 In 2008, Petaluma became an eligible Federal Transit Administration (FTA) grant recipient. The City of Petaluma has utilized these funds to replace numerous vehicles and for various capital projects in the last seven years. The financial viability of Petaluma Transit has improved significantly with the access to this robust funding source for public transportation. DISCUSSION The FTA requires that certain policies and procedures be adopted by recipients of FTA funding. In this case, the City of Petaluma is required to adopt a Title VI (Civil Rights) Program to prevent discriminatory action on the part of the City's transit system. The City will utilize the policies and procedures in the 2015 Title VI Program to ensure fair and non-discriminatory access to the transit system. This will ensure that Petaluma remains eligible for FTA funding. The proposed action meets Council Goal: "Achieve fiscal stability and maintain financial sustainability". FINANCIAL IMPACTS There is no financial impact associated with the recommended action. ATTACHMENTS 1. Resolution 2. 2015 Petaluma Title VI Program Attachment 1 RESOLUTION ADOPTINGTHE 2015 TITLE VI PROGRAM FOR PETALUMA TRANSIT WHEREAS, the Moving Ahead for Progress in the 21St Century (MAP -21) (Public Law Public Law 109-59, July 6, 2012) continues the Federal Transit Administration Formula Programs (23 U.S.C. §53) and Surface Transportation Program (23 U.S.C. § 133); and WHEREAS, pursuant to MAP -21, and the regulations promulgated thereunder, eligible project sponsors wishing to receive Federal Transit Administration (FTA) Section 5307 and Section 5339 grants for a project shall be required to follow all published FTA guidance documents; and WHEREAS, the FTA requires grantees to periodically adopt written Title VI Programs to ensure equal access for all to FTA -funded transit services; and WHEREAS, the City of Petaluma is an eligible project sponsor for FTA Section 5307 and Section 5339 funds and obligated to comply with any and all FTA regulations; and WHEREAS, the City of Petaluma has benefitted greatly from inclusion into the FTA Section 5307 and 5339 Funding Programs, and wishes to continue eligibility for these funds for projects, such as bus replacements, facility renovations, communication equipment procurement, and operating assistance/preventative maintenance. NOW, THEREFORE, BE IT RESOLVED, that the City of Petaluma formally adopts the 2015 Title VI Program for Petaluma Transit, attached hereto and incorporated herein as Exhibit A, which shall apply to all FTA -funded transit programs. 2 City of Petaluma — Petaluma Transit TITLE A Plan July 2015 W; Attachments: A. Public Notice and Complaint Process B. Public Participation Plan C. Limited English Proficiency Plan D. Systemwide Standards and Policies E. Documentation of City Council Approval Attachment 2 3 City of Petaluma — Petaluma Transit Title VI Program July 2015 This program reflects the City of Petaluma Transit Division's ("Petaluma Transit") commitment to ensuring that no person shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity provided by Petaluma Transit, as protected by Title VI of the Civil Rights Act of 1964 ("Title VI"). 11. Title VI Complaint Procedures Background The City of Petaluma has a file established for all Title VI complaints. This file is stored at the transit facility at 555 N. McDowell Blvd, Petaluma CA 94954. The file is available for review by anyone making such a request. All complaints will be investigated by the City of Petaluma's Risk Management Department. A record of the investigation will accompany a copy of the original complaint in the file. Additionally any notification of legal action as well as the results of any legal action will be filed with the original complaint and investigation documents. Procedure Upon receipt of a complaint regarding a violation of civil rights a copy must be made and placed in a folder labeled with the name of the filer and the date, this folder shall be filed in the title VI folder. The original must be submitted to the City of Petaluma's Risk Manager for an investigation. Any additional correspondence from the filer should be handled in the same manner with a copy being filed with the.copy of the claim in the title VI claim folder. Any correspondence from the Risk Management Department pertaining to the claim should also be filed with the copy of the original claim. If the Risk Manager determines it is necessary they will forward the claim onto legal counsel, and any correspondence received from them will be handled in the manner described above. Ill. notice to Public of Rights under Title VI Attachment A shows the Petaluma Transit public notice, discrimination complaint process, and complaint form. This notice is posted on the Petaluma Transit website, Petaluma Transit customer center, and inside transit vehicles in English and Spanish. July 2015 1 4 IV. List of Title VI investigations, complaints, or lawsuits There are no investigations, complaints, or lawsuits currently filed with Petaluma Transit, V. Public Participation Pian Attachment Q is Petaluma Transit's Public Participation Plan, which outlines the strategies for engaging the public in the process of transportation decisions. The plan is used to guide interaction with the community and encourage participation from traditionally disadvantaged populations, including the elderly, people with disabilities, minorities, non- English speaking persons, and low-income populations. VI. Limited English Proficiency Plan Petaluma Transit ensures that persons with Limited English Proficiency (LEP) shall not be discriminated against nor denied meaningful access to, and participation in, the programs and services provided by the agency. Attachment C contains an LEP plan that includes an assessment of current needs and language assistance strategies. VII. Ethnic Breakdown of Transit Advisory Committee African Asian Native Two or Caucasian Latino American American American Other more - Population 80.4% 21.5% 1.4% 4.5% 0.6% 0.2% 4.1% Transit Advisory 83% 17% 0% 0% 0%0% 0% ° ° Committee Notices of vacancies on the Transit Advisory Committee are placed on all Petaluma Transit buses and are sent out to the City's general mailing list. VIII. Narrative Describing Subrecipient Monitoring The Sonoma Marin Area Rail Transit (SMART) District is a subrecipient to Petaluma Transit. Petaluma transit monitors SMART on an ongoing basis to ensure compliance with Title.Vl. SMART provides Petaluma Transit with Title VI programs and documentation of communications translated to Spanish. SMART is currently in the process of becoming a direct recipient. IX. Determination of Site or Location of Facilities Petaluma Transit did not plan, site, or build any new facilities during the last term. There are no new facilities currently being planned. X. Systemwide Service Standards and Policies July 2015 2 5 DRAFT Attachment D contains Petaluma Transit's adopted systemwide service standards and policies. XI, (Documentation of Council Approval Petaluma City Council has approved this 2015 Title VI Plan on May 18, 2015. July 2015 3 6 Petaluma Transit — Title VI Program Attachment A: Public Notice and Complaint Process PUBLIC NOTICE TITLE VI OF THE 1964 CIVIL RIGHTS ACT "No person in the United States shall, on the ground of race, color or national origin, be excluded from participation in, be denied the benefits of, or be.subjected to discrimination under any program or activity receiving federal financial assistance" Petaluma Transit is committed to ensuring that no person is excluded from participation in, or denied the benefits of its services on the basis of race, color or national origin as protected by Title VI of the Civil Rights Act of 1964, as amended ("Title VI"). If you believe you have been subjected to discrimination under Title VI, you may file a written complaint with Petaluma Transit. The complaint must be filed no later than 180 calendar days of the alleged discriminatory incident. The preferred method is to file your complaint in writing using the Title VI Complaint Form, and sending it to: Transit Manager Petaluma Transit 555 N. McDowell Blvd Petaluma CA 94954 Verbal complaints will be accepted and transcribed by the Transit Manager. To make a verbal complaint or to receive more information on Petaluma Transit's Title VI Program, call (707) 778-4421. Complaints may be filed directly with the Federal Transit Administration by filing a complaint with: Office of Civil Rights Attention: Title VI Program Coordinator East Building, 5th Floor —TCR 1200 New Jersey Ave. SE Washington, DC 20590 If information is needed in another language please call (707)778-4421. Si se necesita informacion en otro idioma, por favor Ilame al ( 707) 778-4421. July 2015 A-1 7 Petaluma Transit — Title VI Program Attachment A: Public Notice and Complaint Process Petaluma Transit Title VI Complaint Process Petaluma Transit grants all citizens equal access to all its transportation services. It is further the intent of Petaluma Transit, that all citizens are aware of their rights to such access. This site is designed to serve as an educational tool for citizens so that they may understand one of the civil rights laws that protect their benefit of Petaluma Transit programs and services, specifically, as it relates to Title VI of the Civil Rights Act of 1964. What is Title VI? Title VI is a section of the Civil Rights Act of 1964 requiring that "No person in the United States shall on the grounds of race, color or national origin, be excluded from . participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance." Note that Title VI does not address gender discrimination. It only covers race, color and national origin. Other Civil Rights laws prohibit gender discrimination. Complaint Process How do I file a complaint? If you believe that you have received discriminatory treatment by Petaluma Transit on the basis of your race, color or national origin, you have the right to file a complaint with the Transit Manager. The complaint must be filed no later than 180 calendar days of the alleged discriminatory incident. Methods of filing a complaint The preferred method is to file your complaint in writing using the Title VI Complaint Form, and sending it to: Transit Manager Petaluma Transit 555 N. McDowell Blvd Petaluma CA 94954 Verbal complaints will be accepted and transcribed by the Transit Manager. To make a verbal complaint, call (707) 778-4421. You also have the right to file a complaint with an external entity such as the Department of Transportation (DOT), a federal or state agency, or a federal or state court. July 2015 A-2 Petaluma Transit — Title VI Program Attachment A: Public Notice and Complaint Process Should a complaint be filed with Petaluma Transit and an external entity simultaneously, the external complaint shall supersede the Petaluma Transit complaint and Petaluma Transit's complaint procedures will be suspended pending the external entity's findings. Investigations Within 10 working days of receipt of the formal complaint, the Transit Manager will notify the complainant and begin an investigation (unless the complaint is filed with an external entity first or simultaneously). The investigation will address complaints against Petaluma Transit and Petaluma Paratransit employees and contractors. The investigation will be conducted in conjunction with and under the advice of The City of Petaluma's Risk Manager. The investigation may include discussion(s) of the complaint with all affected parties to determine the problem. The complainant may be represented by an attorney or other representative of his/her own choosing and may bring witnesses and present testimony and evidence in the course of the investigation. The investigation will be conducted and completed within 60 days of the receipt of the formal complaint. Based upon all the information received, an investigation report will be written by the Risk Manager for submittal to the Transit Manager. The complainant will receive a letter stating the final decision of the Transit Manager by the end of the 60 -day time limit. The complainant shall be notified of his/her right to appeal the decision. Appeals may be made to the DOT, the EEOC, or the DFEH. July 2015 A-3 9 Petaluma Transit—Title VI Program Attachment A: Public Notice and Complaint Process Title VI Complaint Form Title VI of the 1964 Civil Rights Act requires that "No person in the United States shall, on the ground of race, color or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance." Note: The following information is necessary to assist us in processing your complaint. Should you require any assistance in completing this form, please let us know. Complete and return this form to: Transit Manager Petaluma Transit 555 N. McDowell Blvd Petaluma CA 94954 1. Complainant's Name 2. Address 3. City, State and Zip Code 4. Telephone Number (home) (business) S. Person discriminated against (if someone other than the complainant) Name Address City, State and Zip Code 6. Which of the following best describes the reason you believe the discrimination took place? Was it because of your: a. Race b. Color c. National Origin 7. What date did the alleged discrimination take place? July 2015 A-4 10 Petaluma Transit — Title VI Program Attachment A: Public Notice and Complaint Process 8. In your own words, describe the alleged discrimination. Explain what happened and whom you believe was responsible. Please use the back of this form if additional space is required. 9. Have you filed this complaint with any other federal, state, or local agency; or with any federal or state court? Yes No If yes, check all that apply: Federal agency Federal court State agency State court Localagency 10. Please provide information about a contact person at the agency/court where the complaint was filed. Name Address City, State, and Zip Code Telephone Number 11. Please sign below. You may attach any written materials or other information that you think is relevant to your complaint. Complainant's Signature Date July 2015 A-5 11 Petaluma Transit — Title VI Program Attachment B: Public Participation Plan City of Petaluma — Petaluma Transit Public Participation Plan I. Introduction The City of Petaluma provides fixed -route transit and paratransit services through Petaluma Transit, a division of the Department of Public Works & Utilities. Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and national origins in programs and activities receiving federal financial assistance. Under federal regulations, transit operators must take reasonable steps to ensure persons have access to their activities and programs. This Public Participation Plan is used to inform the community of available services and to encourage participation from traditionally disadvantaged populations, including the elderly; people with disabilities, minorities, non-English speaking persons, and low- income populations. The Plan includes a summary profile of the City of Petaluma and a description of the public participation strategies undertaken by Petaluma Transit. I1. Community Profile The following summary of the City of Petaluma's geography, social characteristics, and economic characteristics establishes context for this Public Participation Plan. All social and economic characteristics are derived from the American Community Survey 2009- 2013 5 -year Estimates. Geography The City of Petaluma, which is also the Petaluma Transit Service area, covers approximately.14.4 square miles of land. There are 1,581 housing units and 4,028 residents per square mile. California Highway 101 and Washington Street divide the City into quadrants. The Petaluma River runs through the historic downtown on the west side of the City. The east side of the city contains newer neighborhoods and retail centers. There are two Petaluma Transit Transfer Centers located on either side of Highway 101, the Copeland Street Transit Mall (west) and the Eastside Transit Center (east). Social & Economic Characteristics Population & Age Population 58,357 Age 0-19 15,289 26.2% Age 20-64 35,364 60.6% Age 65+ 7,703 13.2% Median Age 40.9 July 2015 C-1 12 Petaluma Transit—Title VI Program Attachment B: Public Participation Plan Ethnicity White alone 48,199 82.6% Black or African Arnerican alone 688 1.2% American Indian and Alaska Native alone 442 0.8% Asian alone 2,537 4.3% Native Hawaiian and Other Pacific Islander alone ` 46 0.1% Some other race alone - 4,520 - - 7.7% Two or more races: 1,925 3.3% Hispanic or Latino (of any race) 12,932 22.2% Education — Population 25 years and older Less than 9th grade 2,008 5.0% 9th to 12th rade nodiploma - 2,231 - -o 5.5/° High school graduate (includes equivalency) 7,813 19.4% Some college, no degree 10,001 24.9/° Associate's degree 3,369 ; 8.4% Bachelor's degree 10,129 25.2% Graduate or professional degree 4,682 11.6% Veteran Status Civilian Veterans 3,747 8.5% Disability Status Total with a disability 5,176 8.9% of population Under 18 years old with a disability 444 3.2% of age group 18-64 with a disability 2,468 6.8% of age group 65+ with a disability 2,264 30.5/ of age group Language — Population 5 years and older English only 40,632 74.6% Language other than English 13,815 25.4% Speak English less than "very well" 5,534 10.2% Spanish 9,444 17.3% Speak English less than "very well" 4,210 7.7% Other Indo-European languages 2,425 4.5% Speak English less than "very well" 577 1.1% Asian and Pacific Islander languages 1,645 3.0% Speak English less than "very well" 730 1.3% Other languages 301 0.6/0 Speak English less than "very well" 17 0.0% Economic Characteristics Median household income 80,243 Average household income 93,319 Living in poverty 9.6% July 2015 C-2 13 Petaluma Transit — Title VI Program Attachment B: Public Participation Plan 111. Public Participation Strategies Petaluma Transit ensures equal access to its programs and services and promotes inclusive participation through the following strategies. ® Implementation of the language assistance measures outlined in the Limited English Proficiency Plan (See Attachment C) ® Participation in community events ® Public meetings are held in the evenings and at a central, transit -accessible location to allow for maximum attendance ® Coordination and partnership with community organizations ® Bilingual outreach at transit centers prior to fare and service changes ® Outreach to schools ® Events at the Senior Center ® Events at senior housing facilities ® Transit maps tailored to each of the four public middle and high schools are distributed in print and posted online in English and Spanish ® Focus groups at the junior college ® Bilingual advertising on buses about opportunities to participate ® Email notice of opportunities to participate are sent to the City's general mailing list ® Videos on how to ride the bus are posted online ® Rider guides for bus and paratransit are provided in large print ® This Plan will be provided on the website in English and Spanish ® Outreach is conducted at transit centers during busy times of day to make participation easier for the most possible riders ® Social media, including Facebook, is used to notify riders of changes or delays July 2015 C-3 14 Petaluma Transit — Title VI Program Attachment C: LEP Plan Petaluma Transit — City of Petaluma Limited English Proficiency (LEP) Plan I. Introduction The City of Petaluma provides fixed -route transit and paratransit services through Petaluma Transit, a division of the Department of Public Works & Utilities. Limited English proficiency (LEP) is defined by the limited ability to read, write, speak, or understand English. Petaluma Transit ensures that persons with Limited English proficiency shall not be discriminated against nor denied meaningful access to, and participation in, the programs and services provided by the division, at no additional cost. This Limited English Proficiency Plan describes Petaluma Transit's strategy for providing language assistance for LEP populations. The Plan includes a needs assessment based on a four -factor analysis, language assistance measures, a staff training plan, ongoing maintenance measures, and notification methods. II. Four Factor Analysis The following analysis is used to determine the appropriate language services that should be provided to ensure meaningful access to Petaluma Transit programs and activities. Factor 1: Number and proportion of LEP persons served or encountered Petaluma used the American Community Survey (ACS) 5 Year survey data for 2009-2013 for Limited English Proficient (LEP) Populations in the City of Petaluma to estimate the number or proportion of LEP persons who might use or want to use Petaluma Transit's services. The American Community Survey (ACS) 5 Year survey data identifies people who speak English "less than very well" as Limited English Proficient persons. Of the population aged five years and older in the City of Petaluma, 7.7% (4,210) speak Spanish at home and are limited English proficient. The following table shows the population broken down by the language that is spoken at home and the ability to speak English. July 2015 C-1 15 Petaluma Transit — Title VI Program Attachment C: LEP Plan Language Spoken at Home in Petaluma' Margin Estimate Margin of Error Percent of Error Population 5 years and over English only Language other than English Speak English less than "very well" Spanish Speak English less than "very well" Other Indo-European languages Speak English less than "very well" Asian and Pacific Islander languages - -- ---._.------- -- -- --- - -- - Speak English less than "very well" Other languages Speak English less than "very well" 54,447 +/-488 -- -- 40,632 +/-1,316 74.6% +/-2.1, 13,815 +/-1,137 25.4% i +/-2.1 5,534 +/-741 10.2% +/-1.4 9,444 +/-1,061 17.3% +/-2.0 4,210 +/-735 7.7% +/-1.4 2,425 +/-452 4.5% +/-0.8 577 +/-219 1.1% +/-0.4 1_,645 +/-339 3.0% +/-0.6 _ 730 +/-197 - - - 1.3% - - --: +/-0.4 301 +/-150 0.6% +/-0.3 17 +/-28 0.0% +/-0.1 Factor 2: Frequency of LEP populations' contact with existing programs, activities, and services Petaluma Transit conducted an onboard survey in April 2014. The survey was offered in both English and Spanish, with 8.1% of the surveys completed in Spanish. Among registered paratransit riders, 2.6% indicate a language other than English as their primary language. Over the last two years, 1% of all new paratransit riders have indicated Spanish as their primary language. Factor 3: Importance to LEP populations of programs, activities, and services Petaluma Transit considers public transit to be an important and essential service for many residents, commuters, and visitors. The majority of onboard survey respondents who answered in Spanish reported a family income of less than $30,000 per year. The American Community Survey estimated that 12% of Petaluma residents who commute to work on public transportation speak Spanish and are LE p2. Factor 4: Resources available to Petaluma Transit and overall cost to provide LEP assistance Petaluma Transit makes a reasonable effort to communicate with LEP persons about available transit services, including the establishment of two bi-lingual staff positions. One of the positions, which is funded by an FTA Job Access & Reverse Commute grant, is for a Latino. Community Outreach Coordinator. The purpose of this position is to improve access, to transit for Latino residents through targeted outreach strategies and travel training. The other bilingual staff position is a customer service representative who can 1 2009-2013 American Community Survey 5 -Year Estimates Z 2009-2013 American Community Survey 5 -Year Estimates July 2015 C-2 16 Petaluma Transit — Title VI Program Attachment C: LEP Plan help Spanish-speaking persons over the phone or in person. Both positions assist with translation of vital documents. Additional LEP assistance strategies are discussed in the following section. III. Language Assistance Measures The percentage of Spanish-speaking LEP persons in the Petaluma Transit service area meets the Safe Harbor threshold by constituting at least 5% of the total population. This means that Petaluma Transit must provide written translation of vital documents in Spanish in order to comply with the Safe Harbor provision, as adopted by the Federal Department of Transportation. Petaluma Transit meets and exceeds this requirement by providing an array of assistance measures for Spanish-speaking LEP persons. Current and planned language assistance measures to address the needs of LEP persons include the following: ® Permanent Staff position for bilingual customer service representative: o Answers incoming phone calls in Spanish a Responds to customer service inquiries in Spanish o Translates key documents to Spanish o Provides oral translation of all documents ® Grant -funded staff position for Latino Community Outreach Coordinator: o Assesses transit needs of Latino community o Fosters ongoing relationships with Latino community leaders and community groups, including LEP advocacy groups o Attends community events o Staffs Petaluma outreach events about fare and service changes o Provides travel training in Spanish o Translates key documents to Spanish o Provides oral translation of all documents • Key written materials that are translated to Spanish: o System map o School -specific transit maps for all public high and middle schools o System advisories o Title VI Public Notice — print and web ® ADA Paratransit services and materials available in any language: o Telephone customer service o Application o In-person evaluation o Paratransit Rider's Guide (only available in Spanish) ® Advertisements in local Spanish-language newspaper announcing fare and service changes ® Website postings informing users of available LEP assistance provided in Spanish July 2015 C-3 17 Petaluma Transit — Title VI Program Attachment C: LEP Plan • Onboard audio announcements are provided in Spanish • Onboard written notices are provided in Spanish • Coordination of oral and written translation services for languages other than English IV. Methods for Notifying LEP Persons About Available Language Assistance Petaluma Transit will notify LEP persons of available language assistance services through the following methods: * Written notices in Spanish and English onboard transit vehicles • Written notices in Spanish and English on display in the transit customer service office • Notice in Spanish and English on the website • Including contact information for translation requests on key printed documents • Posting of bilingual fliers at community centers, libraries, and transit centers • Participation in local community events V. Methods for Monitoring, Evaluating, and Updating Plan Petaluma Transit will review this plan annually, including: ® Assessing sufficiency of staff training and budget for language assistance ® Reviewing current sources for assistance to ensure continuing availability ® Reviewing and complaints, comments, and suggestions related to LEP assistance VI. Staff Training Plan Petaluma Transit will ensure effective implementation of this Plan by scheduling annual trainings for existing staff and by including effective LEP assistance strategies in the orientation training for new staff that regularly interact with the public. Training will include a review of this plan and how to handle verbal requests for service or information in a language other than English. July 2015 C-4 18 Petaluma Transit — Title VI Program Attachment D: Systemwide Services Standards and Policies 1. Systemwide Service Standards and Policies Vehicle Load Standards Mode I Average Passenger Capacities Peak Base Vehicle Type Seated Standing :. Total Max Load Factor ! Max Load Factor -60 60 60 - Peak - Off -Peak Regular Routes Tripper Routes n/a n/a n/a Saturday 30' Gillig LF 23 19 42 42/23 i 42/23 i 35' Gillig LF 34 28 62 62/34 62/34 40' New Flyer LF 38 31 69 i 69/38 69/38 Tripper Routes minutes minutes minutes i 30' n/a n/a n/a 35' Gillig 34 28 62 1 62/34 ' 62/34 40' New Flyer LF 38 31 69 69/38 69/38 Vehicle Fleadways Standards Mode Peak Base Evening Weekday Regular Routes -60 60 60 minutes minutes minutes Tripper Routes n/a n/a n/a Saturday Regular Routes 60 60 i 60 minutes i minutes minutes Sunday i Regular Routes 60 60 60 minutes minutes minutes i July 2015 D-1 19 Petaluma Transit—Title VI Program Attachment D: Systemwide Services Standards and Policies On -Time Vehicle Performance Standards A vehicle is considered on-time if it departs a scheduled timepoint no more than 1 minute early and no more than 5 minutes late, Petaluma Transit's on-time performance objective is 90%. Service Availability Standards Petaluma Transit bus stops will not be more than 4 blocks apart. Vehicle Assignment Policy BUSES ASSIGNMENTS BY SIZE FOR TRANSIT SIZE 30 35 40 MILEAGE 2/11 2ND iST, 3RD 200 3/33 2ND 15T "' 3RD 165 11/2/33 2ND 3RD 200 1/24 QST._ _ 2ND 3RD 155 1T AM 1$T 1 2ND 3RD 110 1T/ 1/24 PM 2ND fiST _ 3RD 3T AM 3RD 2ND 1ST;_ - 80 3T/ 3/33 PM 3RD 2ND 1;T SHDW AM 'QST ) 2ND 3RD 35 SHDW PM 3RD 2ND 'S' ., - 33M 3RD I 2ND `` ST_ -YJ 20 Transit Amenities Policy Petaluma Transit assigns transit stop amenities based on the average count of boardings and alightings, with consideration of site suitability and physical constraints. July 2015 D-2 20